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Privacy Statement


provides an end-to-end programme delivery for central and local governments including: audience insight, stakeholder insight, frontline service provision, promotion, stakeholder recruitment and management, impact reporting.

Spectra Studio

Social impact consulting, including:

CSR strategy and delivery, internal ED&I policy development and project delivery, community engagement strategy and delivery.

The Company must process personal data (including special categories of personal data) so that it can provide these services – in doing so, the Company acts as a data controller.

We may collect information about you because of:

  • Your telephone and/or email enquiries about one of our programmes; you are a current client, stakeholder, or contractor or have completed one of our programmes.
  • You are attending or have attended one of our workshops/events, or you are a newsletter subscriber.
  • For the purposes of providing, you with work-finding services and/or information relating to roles relevant to you, we will only use your personal data in accordance with this privacy statement. We will always comply with current data protection laws.

Collection and use of personal data

Purpose of processing and legal basis

Information you give us. You may give us information about you by filling in forms on the site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you apply for employment, request information on our services, sign up as a Care Leaver Covenant signatory, participate in discussion boards and forums, blogs, members’ portals, or other social media functions, and when you report a problem with the site. The information you give us may include your name, address, email address and phone number, personal description and photograph, amongst other information.

If you have opted-in we may also send you marketing information and news via email/text.  You can opt-out from receiving these at any time by clicking “unsubscribe” when you receive these communications from us.

On some occasions we may be required to use your data for the purpose of investigating, reporting and detecting crime and also to comply with laws that apply to us. We may also use your information during the course of internal audits to demonstrate our compliance with certain industry standards.

We must have a legal basis to process your personal data. The legal bases we rely upon to offer our work-finding services to you are:

  • Your consent
  • Where we have a legitimate interest
  • To comply with a legal obligation that we have
  • To fulfil a contractual obligation that we have with you

Legitimate interest

This is where the Company has a legitimate reason to process your data provided it is reasonable and does not go against what you would reasonably expect from us. Where the Company has relied on a legitimate interest to process your personal data our legitimate interests is/are as follows:

We are committed to respecting your privacy and will only use the information you have given to us in the following ways:

  • To contact you regarding specific programmes that are relevant and/or essential to your relationship with us
  • To inform third parties who have a contractual/legitimate interest or requirement (e.g. payroll accountants, HMRC, government departments)
  • We operate email marketing communications which are used to inform you about our developments, news and any events. You can unsubscribe from this list at any time by emailing  after which will not be contacted in the future unless you personally re-subscribe via our website contact form.

Regarding potential business opportunities, we might want to share your contact details with a potential connection if we feel it might benefit you or Spectra. We will always get your permission before sharing any personal information.

Statutory/contractual requirement

The Company has certain legal and contractual requirements to collect personal data (e.g. to comply with the Conduct of Employment Agencies and Employment Businesses Regulations 2003, immigration and tax legislation, and in some circumstances safeguarding requirements).  Our clients may require this personal data, and we may need your data to enter into a contract with you. If you do not give us the personal data we need to collect In order to comply with our statutory and legal requirements.

Recipient/s of data

The Company will process your personal data and/or sensitive personal data with the following recipients:

  • Payroll service providers who manage payroll on our behalf or other payment intermediaries whom we may introduce you to
  • Auditors who are assessing the compliance and processes of the business to ensure its adherence to all relevant legislation and good practice guidance
  • IT and CRM providers
  • Disclosure and Barring Service (DBS)
  • Spectra Group of Companies
  • Government, law enforcement agencies and other regulators e.g. the Police, Home Office, HMRC, Employment Agencies Standards Inspectorate (EASI), Local Authority Designated Officers (LADOs), Trade Unions.

Information to be provided when data collected not from the data subject

Categories of data: 

The Company has collected the following personal data on you:


Personal data:

  • Name, address, mobile no., email
  • National insurance no.
  • Nationality (through right-to-work check)

Special categories of personal data:

Health information including whether you have a disability

Source of the personal data: 

The Company sourced your personal data/special categories of personal data:

  • Software providers who we use to support our services including
  • Cookies listed in section 7

This information [came/did not come] from a publicly accessible source.

Overseas Transfers

The Company will not transfer the information you provide to us to countries outside the UK and/or the European Economic Area (‘EEA’) for the purposes of providing you with work-finding services. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein.

Data retention

The Company will retain your personal data only for as long as is necessary for the purpose we collect it. Different laws may also require us to keep different data for different periods of time. For example, the Conduct of Employment Agencies and Employment Businesses Regulations 2003, require us to keep work-seeker records for at least one year from (a) the date of their creation or (b) after the date on which we last provide you with work-finding services. We are required to keep your records relating to the right to work in the UK 2 years after employment or the engagement has ended alterable and working time records including your 48-hour opt-out notice annual leave/holiday records 2 years from the time they were created.

Where the Company has obtained your consent to process your personal and special categories of personal data, we will do so in line with our retention policy. Upon expiry of that period, the Company will seek further consent from you. Where consent is not granted the Company will cease to process your personal data and sensitive personal data.

Your rights

Please be aware that you have the following data protection rights:

  • The right to be informed about the personal data the Company processes on you.
  • The right of access to the personal data the Company processes on you.
  • The right to rectification of your personal data.
  • The right to the erasure of your personal data in certain circumstances.
  • The right to restrict the processing of your personal data.
  • The right to data portability in certain circumstances.
  • The right to object to the processing of your personal data that was based on a public or legitimate interest.
  • The right not to be subjected to automated decision-making and profiling; and
  • The right to withdraw consent at any time.

Where you have consented to the Company processing your personal data and sensitive personal data you have the right to withdraw that consent at any time by contacting Zhane Simpson– Data Controller. Please note that if you withdraw your consent to further processing that does not affect any processing done prior to the withdrawal of that consent, or which is done according to another legal basis.

There may be circumstances where the Company will still need to process your data for legal or official reasons. Where this is the case, we will tell you and we will restrict the data to only what is necessary for those specific reasons.

If you believe that any of your data that the Company processes is incorrect or incomplete, please contact us using the details above and we will take reasonable steps to check its accuracy and correct it where necessary. 

You can also contact us using the above details if you want us to restrict the type or amount of data we process for you, access your personal data or exercise any of the other rights listed above.

Automated decision-making

We do not use automated decision-making or profiling



We may obtain data about you from cookies. These are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Cookies also enable us to deliver more personalised content.

Most web browsers allow some control of most cookies through the browser settings.


Links to external websites

The Company’s website may contain links to other external websites. Please be aware that the Company is not responsible for the privacy practices of such other sites. When you leave our site we encourage you to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by the Company’s website. 

Sale of business

If the Company’s business is sold or integrated with another business your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business. Where the sale of the business results in the transfer of your details to a different data controller we will notify you of this.

Data Security

The Company takes every precaution to protect users’ information. 

Only employees who need the information to perform a specific job (for example, consultants, our accounts clerk or a marketing assistant) are granted access to your information.

The Company uses all reasonable efforts to safeguard your personal information. However, you should be aware that the use of email/ the Internet is not entirely secure and for this reason the Company cannot guarantee the security or integrity of any personal information which is transferred from you or to you via email/the Internet.

If you share a device with others, we recommend that you do not select the “remember my details” function when that option is offered.

If you have any questions about the security at our website, you can email our HR team at  

Changes to this privacy statement

We will update this privacy statement from time to time. We will post any changes to the statement with revision dates. If we make any material changes, we will notify you.

Complaints or queries

If you wish to complain about this privacy notice or any of the procedures set out in it, please contact Zhane Simpson– Data Controller.

You also have the right to raise concerns with the Information Commissioner’s Office on 0303 123 1113 or at, or any other relevant authority should your personal data be processed outside of the UK and you believe that your data protection rights have not been adhered to.

Privacy Policy 

We use cookies to ensure that we give you the best experience on our website. If you continue to use this site we will assume that you are happy with it.

Spectra First Limited is a company registered in England and Wales with company number 09191219.